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disregarded because it was an agent of the shareholder or it did
not perform the services or otherwise conduct business. See,
e.g., Commissioner v. Bollinger, 485 U.S. 340 (1988); Roubik v.
Commissioner, 53 T.C. 365 (1969). Petitioner relies on these
lines of cases. In other words, vis-�-vis Dr. Katz, the
corporation should not be regarded as having a separate
existence.
In Bollinger, the taxpayer formed a corporation with which
he entered into a written agreement that the corporation would
hold title to certain improved property as the taxpayer’s “agent
for the sole purpose of securing financing”. Commissioner v.
Bollinger, supra at 342. The corporation would convey the
property on demand and had no obligation to maintain the property
nor to perform any functions with respect to the management of
the property. The taxpayer performed all functions with respect
to the property. On his tax return, the taxpayer claimed
deductions relating to the property. The Government disallowed
the deductions contending that the property belonged to the
corporation and under Moline Properties, Inc. v. Commissioner,
supra, the deductions were attributable to the corporation. The
Supreme Court disagreed and held that on these facts the
corporation was an agent of the taxpayer.
The relevant facts in Roubik were summarized by the Court in
its opinion, as follows:
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